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Home My WebLink About03-6662SHERRY A. DECKER Plaintiff JON P. DECKER Defendant : iN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 1N DIVORCE : 03 -6662' : NO. CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYEWS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SHERRY A. DECKER, Plaintiff JON P. DECKER, Defendant : iN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : CIVIL ACTION - LAW : 1N DIVORCE : : NO. 03- 6 6 6,2, CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. §§ 3301(a)(6L (c). (d) OF THE DIVORCE CODE The plaintiff, Sherry A. Decker, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Sherry A. Decker, who currently resides at 116 North Prince Street, Apartment 2, Shippensberg, Pennsylvania. 2. Defendant is Jon P. Decker, who currently resides at the Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on February 28, 2001 in Pleasant Hall, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since December 27, 2003. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Defendant has offered such indignities to the innocent and injured plaintiff as to render plaintiff's condition intolerable and life burdensome. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that plaintiff or defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Mary Claygpfm~ Kt~ Certified ~,kgal Int6t~ THOM lg M. PLACFZ__g ROBERT E. RA1NS Supervising Attorney ANNE MACDONALD-FOX Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 717/243 -2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me tot he penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date/~,~ -~XS) ' 0.~ S~er ~ Plaintiff ~ SHERRY A. DECKER, Plaimiff JON P. DECKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW IN DIVORCE :NO. 03- L6~-4 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Sherry A. Decker, Plaintiff, to proceed in forma pauperis. I, Mary Claycomb Kulp, of the Family Law Clinic, certified legal intem for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Date: Certifi~/d Legal [!;}fem THOMAS M. PLACE ANNE MACDONALD-FOX The Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 CZ =~ SHERRY A. DECKER Plaintiff VS. JON P. DECKER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : : NO. 03-6662 CIVIL TERM AFFIDAVIT OF SERVICE I, Mary Claycomb-Kulp, hereby certify that I served plaintiWs 3301(a)(6), (c) & (d) Divorce Complaint by hand delivering a true and correct copy to the Defendant, Jon P. Decker, at the Cumberland County Prison, 1101 Claremont Rd., Carlisle, Pennsylvania on January 2, 2004. Date: C 3omb Certifie~gLegal I/~m SHERRY A. DECKER, Plaintiff .ION P. DECKER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE ; : : NO. 03- 6662 CIVIL TERM _AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 30, 2003. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree ofdivome after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date ~- ~'- Ok{ Sherry Decl~ Plaintiff SHERRY A. DECKER, Plaintiff JON P. DECKER, Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : : NO. 03- 6662 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A D1VORCE DECREE UNDER ,~3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before the divorce is granted. 3. I understand that I will not be divorced until a decree of divorce is entered by the Court and that a copy of the decree will be sent to me immediately after it is flied with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications to authorities. Sherry Decl~, Plaintiff SHERRY A. DECKER, Plaintiff Vo JON P. DECKER, Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION-LAW : IN DIVORCE : NO. 03-6662 CIVIL TERM PRAECIPE TO WITHDRAW CLAIM Kindly allow the Plaintiff, Sherry Decker, to withdraw without prejudice her Complaint for Divorce for the following reasons: 1. The Plaintiff, Sherry Decker, filed a complaint for divorce under §{}3301 (a)(6),(c),(d) of the Divorce code on December 30, 2003. 2. The parties reconciled in June of 2004. 3. The parties have resided together since August 2004. 4. Both parties agree to withdrawing the divorce complaint, due to their reconciliation. For the foregoing reasons, kindly withdraw the Plaintiff' s Complaint for Divorce under Certified Legal Intern Lt[cy J~hl~ton-Walsh //~ Amae Ma/cDonald-Fox Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA. 17013 (717)243-2968